Booking Holdings Inc

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Limited Booking Holdings provides only limited transparency around its climate-related lobbying. It indicates that it has engaged on climate policy areas such as mastering “the twin transitions of digitization and decarbonization,” improving sustainability labels, and has referenced work on the EU’s prospective green-claims regulation, but it does not set out a fuller list of the specific bills, directives or rulemakings it has sought to influence. The company does explain a variety of ways it lobbies—saying it takes part in “parliamentary discussions, consultations, bilateral stakeholder meetings, events, meetings with industry associations, public policy forums, media briefings, conferences and conventions” and that it registers its activity on the EU Transparency Register—yet it names few concrete policymaking targets beyond a general reference to collaboration with the EU and “governments and regulatory authorities.” The public positions it seeks are somewhat clearer: it states a desire to help the accommodation sector reach net-zero greenhouse-gas emissions by 2050, to promote “digitization and decarbonization in the tourism sector,” and to expand the use of reliable sustainability labels so that “greenwashing does not take place.” While these aims show the direction of its advocacy, the company stops short of detailing the precise legislative or regulatory changes it presses for, leaving its climate lobbying disclosures only partially transparent overall. 1
Lobbying Governance
Overall Assessment Comment Score
Limited Booking Holdings’ disclosures suggest that its Board of Directors and senior committees receive regular briefings on public affairs and sustainability, yet the company does not disclose any dedicated climate-lobbying governance framework. For example, it "report[s] our advocacy activities to the European Union Transparency Register (and similar public databases)" and "make[s] positions transparent on a public policy blog," and "annually present[s] our public affairs strategy to our Board of Directors and provide written updates throughout the year as required," indicating that the Board has visibility into its lobbying. However, there is no policy or process to ensure that lobbying aligns with its climate objectives, and when asked about alignment with the Paris Agreement, the company replied plainly "No, and we do not plan to have one in the next two years." Additionally, while the company notes that "Our Sustainability Steering Committee is responsible for signing off on Booking Holdings’ overall sustainability strategy, goals, and deliverables," we found no evidence that this committee or any other body oversees or manages the alignment of its direct or indirect lobbying activities with its climate commitments. As a result, the organization provides limited transparency on how it governs or aligns its lobbying with its stated sustainability or climate goals. 1